Income Tax Severed Letters - 2022-08-10

Ruling

2021 Ruling 2021-0906111R3 - XXXXXXXXXX Post-mortem Pipeline

Unedited CRA Tags
84.1; 84(2); 104(4); 245(2)
Summary Under
Tax Topics - Income Tax Act - Section 84 - Subsection 84(2)
pipeline transactions of an alter ego trust implemented over an extended period

Principal Issues: 1) Whether section 84.1 applies to deem the alter ego trust to have received a dividend on the disposition of shares to the new corporation. 2) Whether subsection 84(2) applies to the proposed transactions. 3) Whether subsection 245(2) applies to the proposed transactions.

Position: 1) No. Favourable ruling given. 2) No. Favourable ruling given. 3) No. Favourable ruling given.

Reasons: Based on the provisions of the Act, jurisprudence and CRA publications.

Technical Interpretation - External

24 February 2022 External T.I. 2021-0893701E5 - Indian Act Tax Exemption & Moors

Unedited CRA Tags
Indian Act s.87; 81(1)(a)

Principal Issues: Is the income earned by an individual, who identifies as a member of the Moorish Americans, exempt from tax?

Position: No.

Reasons: Paragraph 81(1)(a) of the Income Tax Act and section 87 of the Indian Act provide an income tax exemption for individuals who are registered or entitled to registered under the Indian Act and whose income is situated on a reserve.